Conduct of Operations Documentation Improves Safety and Efficiency

Conduct of Operations Documentation – what is it, and why does it matter? To start with, let’s take a look at the concept of Conduct of Operations. This is a term used to describe how operations are to be conducted in one’s facility, by all personnel whatever their job title and description might be. It is the expectation of how work is to be done. Documenting that expectation, then, consists of writing these expectations down in an official company document and ensuring that personnel are trained on them. This is important because it permits all personnel to be able to know (and refer back to) what those expectations are at any given time, where they should go if assistance in meeting those expectations is required, and identifies disciplinary actions that will result from failure to abide by those expectations. Compliance with Conduct of Operations requirements helps to enhance worker and process safety, as well as plant efficiency.

WHY IS IT NECESSARY?

Conduct of Operations documentation (and training) requirements is more than simply saying, “Do this job this way, because I said so.” The goals are to enhance the effectiveness of every worker, improve their safety, and minimize variations in performance of their tasks. This helps to institutionalize the “culture of excellence” that is desired, and for workers to take ownership of things like personal responsibility for safety and effectiveness. When someone understands not only WHAT they are being asked to do, but also WHY it is important that it be done correctly, it’s much easier to get workers to “buy-in” and comply with those requirements. Complete Conduct of Operations documentation provides instructors and plant management with a concrete source of information to refer to. Being able to point to safety analyses and documented process improvements are far more real to most workers than simply saying, “This is the way things must be done.” This applies for everything from conducting operator rounds, tracking unit performance, keeping within plant operating limits, performance of corrective and preventative maintenance, following approved procedures on plant components, adhering to Safety Data Sheet requirements when using hazardous materials, and proper use of personal protective equipment. Every aspect of worker performance and interaction with any part of the plant can either contribute to a record of safety and excellent performance, or detract from it.

ABNORMAL CONDITIONS AND TROUBLESHOOTING

This ownership of plant conditions and operating excellence does not apply solely to regular operation. Response to abnormal conditions is equally important, not only in correcting the condition on the spot but also in recognizing what led to that abnormality in the first place and how it might be avoided in the future. A company which visibly and documentedly desires to understand why something bad happened and how best to prevent a recurrence, will have workers keeping a sharp eye on processes and reporting potential issues before they become issues. But for potential issues to be avoided, documentation is vital – or else people don’t necessarily know what has happened in the past and how it was stopped or avoided. Up-to-date Conduct of Operations documentation allows workers to learn from past mistakes and accidents (their own or others’) is as important as looking forward to what is desired, and is arguably more important from a safety standpoint. People typically learn best and most completely from mistakes, so allow that learning to happen! From a training point of view, another way to increase worker buy-in is to involve them in discussions of past events or near-misses and ask what they might have done differently that would have resulted in a better outcome. This is where it is vital to have that documentation of events and near-misses to present to your workers.

COMMUNICATIONS

Another area covered by Conduct of Operations documentation is how information is to be communicated. It is surprisingly easy for people to misinterpret or misunderstand what another person is trying to say, especially when communication is taking place in some way other than directly face-to-face (such as over a phone or two-way-radio connection). Having a formal and documented way of passing information between plant personnel will reduce the possibility of this happening. One way in which communication of information can be made less ambiguous is to use a phonetic alphabet when communicating information including individual letters, which reduces the chance of a recipient mishearing a “G” as an “E”, for example. In such a case, stating “Golf” instead of “G” removes any possibility of misunderstanding. It is also common in many power and industrial plants for a formal expectation of “repeat-backs” or “three-way communication” to be performed. This communication method is used in order to reduce misunderstandings – the person making the initial communication (often relaying an order to perform some task to a field operator) states the desired information – “Open Chilled Water Hand Valve-123 and observe pressure change on the attached pressure gauge,” for example. The field operator states something to the effect of “Understand I am to open Chilled Water Hand Valve-123, and watch the pressure change on its pressure gauge.” If the repeat-back was correct, as in this case, the first person would say, “Correct,” allowing the worker to proceed with the task. If there was an error in any portion of it, they have the opportunity to make an on-the-spot correction to make sure the wrong action is not taken. If the repeat-back had stated Chilled Water Hand Valve-23 instead of -123, the first person would respond with, “Wrong, open Chilled Water Hand Valve ONE-twenty-three, and observe pressure change on its gauge.” This process continues until it is obvious to both, or all, parties to the communication exactly what the information being communicated is. Formalizing communications requirements in this manner can help ensure that correct information is relayed and incorrect actions are not taken in the first place – an obvious method of improving both efficiency and safety.

IN CONCLUSION

From all of this, we can see why it is highly desirable to not only have expectations for Conduct of Operations at a plant but to have these expectations written down and trained on. As well, both the expectations and training should be revisited on a regular basis – like any information, it is possible for changes to be made, and these changes need to be disseminated to staff just as the original information was. Unless prompted by an emergency, it is unlikely to be necessary to do so more than on an annual basis. Either outside or in-house staff should formally document these expectations, and begin a regular training program on them, which will help both the workers and company reap the benefits in safety and improved performance.

Eric Tank is a Staff Specialist at FCS. After six years in the US Navy’s Nuclear Power program as a reactor operator, Eric served as an operator at a civilian nuclear power plant for eight years, followed by seven more as an operator at a major metro area water production plant. Eric has spent the past four years at FCS providing procedure-development and training services to clients in the power generation, transmission, and distribution industry. He may be contacted at etank@fossilconsulting.com for more information.